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(o2 City of Cuyahoga Falls, Ohio 41 AA o AA Analysis of Impediments to Fair Housing Choice due to the popularity of refinancing over the last few years or it could show the increase in the sub prime market in the City which usually show higher denial rates than conventional lenders. Government backed applications (FHA/VA) accounted for 8.3% of total applications, Table 28 shows the breakout of applications by loan type (Conventional, FHA, VA). The important factor of this table is the "not available" reporting percentages. The "not available category" had over 1,609 applications, 34% of all applications received in the City. The high numbers of applications with race "not available" is not limited to Cuyahoga Falls but is a national problem. According to Jason Dietrich, Office of the Comptroller of the Currency, "HMDA contains a surprisingly high percentage of applications that lack race data and those percentages have trended upward. "66 The FFIEC website highlights in its guide to HMDA reporting for 2003 the requirement, effective on January 1, 2003, to collect race and sex data on telephone applications '67 This new requirement will allow more accurate monitoring of lending institutions for fair lending compliance. But just as that new effort was recently put into place, the regulatory agencies in late 2004 were considering changes to HMDA reporting requirements that would make it difficult to continue to get HMDA data from a large percentage of lenders in the Country. loans had the lowest rate of denials, with just over 5.3% in 1999 the highest year. It would be expected that these loans would have lower rates since they are designed for those with credit problems and other lending issues. 7.5 City of Cuyahoga Falls's Largest Lenders As mentioned earlier of the 251 lenders active in the Cuyahoga Falls in 2002 the majority received 20 or less applications. For this report we considered all lenders who had 2% of more of the lending market. Table 29 indicates the thirteen lenders that meet that criteria. Sub prime lenders are highlighted. As discussed previously five of the thirteen largest lenders are sub prime with a total market share of just over 20 %. The two largest lenders were Countrywide Home Loans and ABN AMRO Mortgage Company with 12.7% of the City mortgage market. Four of the largest lenders were had a strong presence in the community through branch offices, National City (3.7 %), Charter One (3..6 %), Bank One (2.8 %), Ohio Savings Bank (2.2 %), and Third Federal Savings and Loan (2.0 %). Two of the local lenders also showed a presence with their affiliated mortgage companies, National City Mortgage Company ( 3.7 %) and Firstmerit Mortgage fie Dietrich, Jason, Missing Race Data in HMDA and the Implications for Monitoring of Fair Lending Compliance ", March 2001 67 Federal Financial Institutions Examination Council's website www.ffiee.gov /hmda, September 12, 2003